1. Admit your mistake. Do this in writing. Identify this fault in your Program Evaluation Committee Minutes. Send an email or copy of the minutes to your Governing Body so they are kept in the loop.

2. Show your plan for future compliance.

3. Never, Never, Never try to back date something. Full disclosure is better than trying to hide something. If you messed up, fine admit it and move on. Just don’t let it happen again.

4. Don’t just attach a bunch of computer printouts to your Program Evaluation Committee Minutes. This only proves one thing…you know how to use a binder clip! CMS wants to know that you are providing real analysis.

5. Don’t get discouraged. Program Evaluation is a snapshot of what you did clinically, operationally and financially during the past span of time. It’s a systematic and overall.

6. Just because CMS asks for a “statistical analysis” doesn’t mean they want you to go into some statistical dissertation. They only want you to analyze your data and use it to better your practice. Remember, the rules are designed to look out for the Medicare beneficiary…. You know this person as “your patient!”

7. Don’t forget to include Policies and Procedures to support your Program Evaluation function.

8. Chart Reviews or Clinical Record Audits are NOT Quality Assurance; and NOT Utilization Review. These are not interchangeable terms. They have their specific scopes of concern.

Chart Reviews: This is Quality Control in making sure the construction and components of the chart are in place. Example – “Is there an Initial Evaluation?”

Utilization Review: This metric evaluates numbers of resources used in a Rehab Agency. Example – Lengths of Stay, Visits per Referral or Salary Cost per Visit are good examples of Utilization Review.

9. Always use your Committee Minutes to support any questions or gaps. This is a great place for “filler” that helps explain what you did (or didn’t do.) Don’t just state facts or regurgitate data. Explain it!

10. Develop a master calendar to show all your meetings. Your CMS surveyor will be impressed that you are thinking ahead. Remember, you may have forgotten to hold your meetings last year. Why not start off this year with a plan and stick to it!

If you need help getting started, please review our free Program Evaluation templates. Good luck with your Program Evaluation. For further assistance on this or other Medicare certification compliance matters please contact Jeff Dance at KeySys Health. jdance@keysyshealth.com

Note on the author: Jeff Dance has more than 20 years experience in Medicare certification compliance. He has managed more than 2,000 certifications in all 50 states and consults with healthcare providers in all disciplines. KeySys Health offers a wide range of healthcare consulting services to small and medium sized practices.